Form 8840 question

I have struggled with this form (8840) for a while now. Here's the reason why. I have sold my home in Canada. I have a permanent address in Canada inasmuch as my wife's sister and brother-in-law have a complete suite furnished in their basement and said that we have a bona fide residence there. We have our driver's licences in Alberta, we pay taxes in Canada. We own a home in Mesquite, Nevada and will shortly be moving to Panama as full-time permanent residents, except for the odd trip to the U.S. When we fill in the 8840 form, what risks do we run with the IRS by saying that we have a "closer association" with the U.S. because our only personally owned home is in Nevada? I would be very appreciative of an answer to this question.

Ken Carter
Calgary, AB

Response :Ed.: That’s easy; when you file your 8840, you still have a closer connection to Canada. When you move to Panama, you will have a closer connection to Panama and should still file the 8840. We see no risk.